Code of Conduct


OPALai Pte Ltd (the “Company”) has adopted a Code of Conduct (this “Code of Conduct”) that applies to all employees. This Code of Conduct sets out the principles to guide its employees in carrying out their duties and responsibilities to the highest standards of personal and corporate integrity when dealing with the Company, its competitors, customers, suppliers, other employees and the community, and the minimum standard that the Company expects of its employees regardless of the jurisdiction or legal entity through the Company operates. Where appropriate, this Code of Conduct can be supplemented by additional specific requirements. It is the responsibility of every employee to comply with the spirit and principles of this Code of Conduct, as may be amended by the Company from time to time.

Workplace health and safety

The Company is committed to provide a healthy and safe work environment for its employees. All employees are obliged to observe the rules of office security, and carry out their work in a safe manner, without causing harm to themselves or others, and to report any potentially unsafe or unhealthy situations immediately. While on duty, employees must not conduct themselves in such a manner that will interfere with or prevent other employees from carrying out their duties properly. Employees must attend work in a fit state and not be under the influence of alcohol or drugs during working hours. Any involvement with the manufacture, possession, use, distribution, sale, purchase, or transfer of illegal drugs is strictly prohibited.

Dealings with other employees

The Company is committed to providing its employees with a work environment which is conducive, safe, and free from discrimination and harassment. Employees should always treat their colleagues and other persons with respect and consideration. Workplace harassment can occur when one party demonstrates behavior that causes or is likely to cause harassment, alarm, or distress to another party, including but not limited to threatening, abusive, or insulting language, comments or other non-verbal gestures, discrimination, physical violence, cyber-bullying, sexual harassment, and stalking. Workplace harassment can also take place through different modes of communications, e.g., email, text messaging or social media. The Company will not tolerate any acts of discrimination or harassment and will investigate all complaints and incidents in a fair and timely manner.

The Company further prohibits any form of retaliation or intimidation against any person for making good faith reports concerning allegations of discrimination, harassment, violation of this Code of Conduct, or any other allegations of improper behavior. Any employee, who is found guilty of such acts shall be subject to disciplinary action, which may include termination/dismissal from service.

Work performance

The Company is committed to providing quality and efficient service to all customers, and every employee has an important role to play. All employees are required to perform tasks assigned in a responsible and reliable manner, including managing time at work and resources efficiently. They must act sensibly and conduct themselves whether at work or outside of work in a manner that upholds the Company’s integrity, reputation, and values.

Compliance with law

The Company expects its employees to comply with all laws, regulations, codes of practice, and legal, regulatory, and licensing requirements applicable to the different jurisdictions where it operates. Employees should not engage in any activity that adversely affects the Company’s interests or reputation.

Confidentiality of the Company’s confidential and proprietary information

Employees may receive and/or have access to secret, confidential or proprietary information relating to the Company or any other person (i) in which the Company may have an interest (equity or otherwise) or (ii) to whom the Company owes an obligation (whether pursuant to a contract or otherwise). Employees are allowed to disclose or divulge or cause to be disclosed or divulged such information without the Company’s prior written approval. This condition shall continue to apply even after they are no longer employed by the Company.

Employees who have access to and/or collect, use disclose, or process personal data of external parties or other employees should exercise caution when discussing such confidential information in open workspace areas, such as cubicles, speakerphones, mobile phones and other communication devices, and refrain from discussing such confidential information in public places. In addition, employees are responsible for complying with the Company’s policy on protection of personal data to ensure compliance with applicable personal data protection laws and regulations.

Conflict of Interest

Employees should not engage in any outside business dealings that involve or could appear to involve, a conflict between their personal interests and the Company’s interests (i.e., conflict of interests). Employees must not have any direct or indirect financial or business interest in or dealings with competitors, suppliers, customers, or anyone else with whom they are engaged in a business relationship on behalf of the Company which may or may appear to create a conflict of interest or impair the judgments they make on behalf of the Company. It is not possible to list every situation that could present a conflict of interest, so the Company relies on employees to exercise good judgement and avoid situations that may affect their objectivity in making decisions as an employee. If any employee is unsure whether an actual or potential conflict exists, such employee should contact the board of directors.

Employment outside the Company

Employees should not engage in any outside employment or hold any external position without the Company’s prior written permission. If they have been given permission to take on such external employment or appointment, they must ensure that these activities do not negatively affect their ability to perform their duties fully and effectively for the Company and its reputation.

Dealing with the media

All media requests for information and interviews should be referred to the board of directors of the Company. No comments regarding the Company, its business, products, services, strategy, or practices should be made without prior approval from the board of directors of the Company. Where employees do participate in blogs or any other online space, even personal sites maintained outside of work hours, they should also take care to ensure that they do not act in conflict with the best interests of the Company.


The acceptance of gifts or hospitality events/invitations from customers, existing and/or potential, business partners, suppliers, contractors, competitors, or members of the public is prohibited as it may create a situation of conflict or potential conflict of interest. Where circumstances make it impossible, difficult, or impractical to reject the gifts or hospitality events/invitations, employees should immediately declare such gifts or hospitality events/invitations to the board of directors of the Company. When in doubt whether the gift or hospitality event/invitation can be accepted, the employee should declare.

As business lunches/dinners are an accepted mode of hospitality, these need not be declared but care must be exercised while accepting such meals. These should be infrequent and non-lavish. The sole purpose must be for enhancement of a business relationship and not for reciprocity. It is also the Company's policy not to accept hospitality events or invitations which involve air travel and/or accommodation. Employees may accept such invitation only if the cost of the air travel and/or accommodation (including related expenses) is fully borne by the employee's unit and with prior approval by the Company.

Further, due consideration should be given to gifts or benefits extended by employees to external parties in public or private sector. It is the responsibility of the employee extending such a gift to ensure that such gift has been approved by the Company and which is deemed reasonable and consistent with the purpose and hence not misconstrued as a bribe or in contravention with any existing Corrupt Practices Act, or other prevalent legislation, in any country where the Company conducts business, including Singapore.


The Company is committed to high standards of probity and accountability in its affairs. It recognizes the importance of protecting its operations, employees and assets against fraud risks and unethical practices, and therefore adopts a “zero tolerance” approach to fraud, corruption, and any other form of criminal conduct. Where an employee has concerns or receives information about any fraud, corruption, or other form of criminal conduct in connection with the Company’s affairs, it is the employee's responsibility to report those concerns or information to the Company.

Suspicious transactions

Under Singapore law, all persons are generally subject to mandatory reporting obligations relating to anti-money laundering and counter terrorism financing under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act and Terrorism (Suppression of Financing) Act. Any person who contravenes the relevant provisions shall be guilty of an offence.

All potential customers of the Company must be verified, including screening against publicly available lists of individuals and entities known, or suspected to be related to a terrorist or a terrorist organization and its financing. The Company would also monitor, on an on-going basis, the business relationships with its customers depending on the risk profiles of such customers. If any employee encounters a situation that seems suspicious, it is the responsibility of the employee to escalate any concern or issue should contact the board of directors.

Ethical breaches

If any employee encounters a situation that seems unethical or improper or which may put the Company or its customers at risk, it is the responsibility of the employee to escalate any concern or issue should contact the board of directors.

Security breaches

In case of an occurrence of a system, service or network state indicating a possible breach of security of Company information or an unknown situation that may compromise business operations with an impact on the security of Company information, it must be promptly escalated and should contact the board of directors.


Failure to comply with this Code of Conduct is viewed as a serious matter that can lead to disciplinary action, up to and including termination of employment or dismissal, as well as criminal penalties. Such disciplinary action may also be taken against supervisors who condone, permit, or have knowledge of improper conduct.

Record Keeping Obligations

In all instances that a transaction with a customer is concluded, the records of the transaction must be retained. This obligation refers to all new and existing clients. In instances where a transaction was not concluded but a suspicious report was made, the records shall be retained as prescribed. Information on customers shall be updated if additional goods/services are purchased by such customers or amendments are made to existing goods/services. Records are kept for a period of 5 years from the date of concluding a single transaction, death of a client, termination date of the business relationship or maturity of the product. Records are kept in electronic formats. The following records shall be obtained and retained in instances of concluding a single transaction, concluding transactions as part of a business relationship or establishment of a business relationship: (i) particulars of customer, (ii) if the customer acts on behalf of a third party and if yes, the particulars of the third party and a copy of the mandate between the customer and the third party, (iii) exact nature of the transaction or business relationship; and (iv) the monetary value of the transaction; (v) KYC information and documents furnished by the customer.

Reservation of the Company’s rights

The Company reserves the right to interpret, terminate, or revise this Code of Conduct, wholly or partly, without notice. Statements within this Code of Conduct that may result in discipline do not limit, in any way, the Company’s right to discipline employees for conduct not specifically described herein. This Code of Conduct shall not be construed as an employment contract or to alter any employee’s status. Employees and the Company remain free to terminate the employment relationship at any time, with or without cause or notice, in accordance with their respective employment contracts.